Page 12 - Compliance Monthly - December 2019

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AML News

Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combating the Financing
of Terrorism Deficiencies and Relevant Actions by the United States Government

On October 18, 2019, the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic anti-money laundering
and combating the financing of terrorism (AML/CFT) deficiencies. The changes may affect U.S. financial institutions’
obligations and risk-based approaches with respect to relevant jurisdictions.

The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to inform financial institutions of updates to the FATF
list of jurisdictions with strategic AML/CFT deficiencies. Financial institutions should be aware of these changes, which may affect
their obligations and risk-based approaches with respect to these jurisdictions. The advisory also reminds financial institutions of
the status of, and obligations involving, these jurisdictions, in particular the Democratic People’s Republic of Korea (DPRK) and Iran.

Source: FinCEN, Publication Date: November 12, 2019.
https://www.fincen.gov/sites/default/files/advisory/2019-11-12/FATF%20Advisory%20October%202019%20FINAL_508.pdf

FinCEN Reissues Real Estate Geographic Targeting Orders for 12 Metropolitan Areas

The Financial Crimes Enforcement Network (FinCEN) renewed of its Geographic Targeting Orders (GTOs) that require U.S. title
insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.
The purchase amount threshold remains $300,000 for each covered metropolitan area.

These renewed GTOs will be identical to the May 2019 GTOs with one modification: the new GTOs will not require reporting for
purchases made by legal entities that are U.S. publicly-traded companies. Real estate purchases by such entities are identifiable
through other business filings. The GTOs cover certain counties within the following major U.S. metropolitan areas: Boston;
Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and
Seattle.

The terms of this Order are effective beginning November 12, 2019 and ending on May 9, 2020.

Source: FinCEN, Publication Date: November 8, 2019.
https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-12-metropolitan-areas-0

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